In the case of State of Kansas v. Burleson, Postmaster General, et al., 1918, the Supreme Court dealt with a dispute between the state and federal government over control of liquor distribution during Prohibition. The state of Kansas had enacted laws to regulate alcohol within its borders but faced opposition from Federal Postmaster General Albert S. Burleson who refused to deliver mail containing liquor advertisements in accordance with federal law prohibiting such activity in "dry" states like Kansas. The court ruled against Kansas stating that under the Supremacy Clause (Article VI) of U.S Constitution which establishes that federal law takes precedence over conflicting state laws; hence it was unconstitutional for a state to interfere with federally controlled activities such as mail delivery even if those activities conflicted with local prohibition laws.

The dissenting opinion in the case of State of Kansas v. Burleson, Postmaster General, et al., 1918 was delivered by Justice Holmes. He argued that the majority's decision to uphold a federal law prohibiting states from regulating interstate commerce violated principles of federalism and state sovereignty. According to him, while Congress has broad powers under the Commerce Clause to regulate interstate commerce, it does not have unlimited power to interfere with state laws or regulations unless they directly conflict with federal law or policy. In this case, he believed there was no such conflict and thus saw no reason for striking down Kansas' regulation on liquor transportation within its borders as unconstitutional interference with interstate commerce regulated by Congress through postal services legislation.